shnorr | Privacy Policy

What Information do we Collect about You and Why?

We collect information from you so that you can log onto our Sites and use our Services. These activities provide you with the opportunity to, (1) if you are an individual consumer, donate to your favorite organizations and causes, create a fundraising or team page; and (2) if you are a client of Shnorr, set up peer-to-peer or crowdfunding efforts, create donation pages, and set up registration on your own behalf or for your organization’s own supporters for activities (collectively, “Campaigns”). We also collect information from businesses, organizations, and individuals who request information from Shnorr or apply to Shnorr’s job postings.

Individuals (and agents of individuals) who provide us information directly or indirectly by donating to or participating in a Campaign or by otherwise using our Services in an individual capacity are referred to herein as “Consumers.” For example, Consumers may enter information in order to donate to a Campaign, or someone who has organized a team or a community as part of a Campaign may enter your information on your behalf. In addition, individuals or organizations can use our Services to set up Campaigns in order to provide Consumers the opportunity to donate, participate, create team fundraising pages , or otherwise interact with such Campaigns (those who use our Services to provide these opportunities to Consumers are referred to as “Clients”). Relatedly, our Clients (including agents or representatives of our Clients) may provide us personal information about individuals who have registered for a Campaign being operated by our Client or who the Client wants us to contact or otherwise provide Services to on behalf of the Client.

When you participate in a Client’s Campaign, we provide your personal information to the Client. This Policy does not cover our Clients’ use of your personal information outside of our Services. We are not responsible for the privacy practices of our Clients, as such we encourage you to read their respective privacy statements. Further, you may be presented with opportunities to purchase products or services offered by third parties or you may elect to participate in contests or sweepstakes offered or sponsored by third parties on the Site. We are not responsible for any such purchase you make, or participation you undertake, and as such any such purchase or participation will be subject to the relevant third party's terms and conditions.

When Clients or Consumers contact us for support or other customer service requests, we maintain support tickets and other records related to the requests, including any information provided by such individuals related to such support or service requests. We may also collect call recordings related to support, customer service, and sales-related calls.

Information We Collect Directly From You and How It May Be Shared

Account Information for our Sites. You may browse our Sites without creating an online account or providing us with your information, but to use certain features or to participate in certain Campaigns, you may need to create an account or otherwise provide us with information. When you create an account with us or participate in a Campaign, we may ask you to provide the following:

Your first and last name;
Your physical address for billing purposes;
Your email address and your desired password;
Your display name (this is the name other people will see when you post items to one of our Sites, make a publicly visible donation, or engage in other similar activities on our site);
Other data requested by Clients using custom question fields;
The contact information of a friend, other members of your team, or your customers (when inviting them to visit the Site or when you are allowed to set up an account for them);
Activity data such as your donation history, fundraising history, events attended, etc.;
Your name, contact information, and financial information;
Your organization’s name, tax identification number, title, 501(c)3 or tax-exempt status, and other information about your organization, if you are a Client or prospective client;
Payment information, such as credit card or financial account numbers (if applicable).

Creating a Client Account. Each Client that registers with the Sites is automatically created an account profile. This profile displays the Client’s active Campaigns. It also displays the total amount the Client has raised per campaign and the number of donors who supported each campaign. Each account profile may include an activity feed that displays activity occurring on the Sites related to that Client (e.g., donations made, events posted, etc.). These account profiles may be publicly accessible using the search function within the Sites or by external search engines (unless, where the functionality is available, the account profile has been made “private” by the Client).

Consumer Transactions. When you make a transaction through the Sites, we may index it for you in an individual profile specific to you. That information remains hidden from the public. If you activate your profile, then you will be able to see your profile when you are logged in. The information in your profile remains inaccessible to the public after you activate it; in order to prevent unauthorized access to your profile, you should not share your login information with other people.

Donations. When you make a donation via the Sites, other Services, or a partner website that uses Shnorr’s donation processing services, you may be asked to share certain information with the recipient charity(ies), including your credit card/financial information and contact information. When a Consumer has asked to remain anonymous, this only hides your name from public activity feeds, not the underlying charitable beneficiary. If you make a donation to an individual fundraiser (i.e. via a peer-to-peer page) but do not donate anonymously, then the person who created the fundraising page will also have access to your personal information (except for your credit card number or financial information). If you make a donation through an individual fundraising page associated with a fundraising team, or directly to a team fundraising page, then the team manager will have access to your personal information (except for your credit card number or financial information).

Charitable Campaigns/Fundraising. If you are a Client, you may create a variety of different types of pages on our Sites in connection with your Campaigns (“Campaign Pages”). Likewise, if you are a Consumer, you may create one or more pages on certain of our Sites in connection with your support of a particular charity. We may collect information from you in the process of your creation of these Client Pages or Consumer Pages, as well as in connection with your creation of, administration of, or participation in, a Campaign.

Public Campaigns. Any Campaign (including all associated Client Pages), will be publicly available unless it is set to “private” (or similar designation such as “Password Protected”), where that functionality is made available, by the Client responsible for creating the Campaign. Unless set to “private” or similar designation, where that functionality is made available, all such Campaign pages created on the Sites are indexed by search engines and accessible to the public. Information that you post on event pages, campaign pages, personal fundraising pages, or other public pages on the Sites can be accessed by other people. You should exercise caution when deciding to share information on public pages. We cannot control who accesses shared information or how other parties will use that information.

User Profiles, Comments, and Posts. Some of our Sites and Services allow users to create or post content such as information about the campaign, their fundraising team, and similar information. If you provide content to our Sites, we may collect and use that information as described in this Policy. Please note that such information may be viewed, collected or used by other registered users and public visitors to our Sites. Once posted, we cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.

Surveys and Questionnaires. We may send out post campaign questionnaires, use automated surveys and use other forms of questionnaires to assess functionality, user satisfaction, and gather information. When you complete questionnaires or surveys, we collect the information you submit to us. We use this information for research purposes, to comply with legal requirements, and for other purposes as discussed in this Policy. This information, such as impact and financial data, may be shared with Partners (as defined below) to appear on their websites and may also be published and used by Shnorr.

Information We Collect Automatically. We may use cookies, web beacons, tags, scripts, and other automated devices to collect information, including personally identifiable information, about you when you visit our Sites and receive emails from us. Specifically, we may collect the following information about your use of our Sites via these technologies: your browser type and operating system; web pages you view; webpage interaction, including cursor movement and links you click; your Internet Protocol (“IP”) address; your approximate geographic location; your interaction with the Sites; length of time you are logged in to our Sites; your unique ID which is given to each visitor and expiration of date of the ID and websites visited before or after our Sites. In some of our links, we use a “click-through URL” linked to content on the Shnorr website. When Consumers click one of these URLs, they pass through a separate web server before arriving at the destination page on our Site. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our Consumer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in different online outlets and paid search results. We also collect non-personal data (including, without limitation, of the type set forth above) from third parties. The information we collect from third parties may be combined with the information we collect directly. This information also may be associated with your username and combined with other information, including personally identifiable information that we collect about you.

This data allows our Sites to function properly, including, by ensuring the proper display of content; creating and remembering your account login details; interface personalization; improving our Sites; and securing our Sites and protecting against fraud. This data is also used to run statistics to avoid visitors being recorded twice, to understand users’ reaction to our advertising campaigns, to improve our offers, to provide a mechanism to share content on social media, to show online advertisements for products or campaigns that may be of interest to you (based on your previous behavior), and/or ads and content on social media platforms or other sites.

For more detailed information on our use of cookies and other tracking technologies, please contact us here.

Information Collected by Clients. Our Clients may place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Sites related to that particular Client. Please refer to that party’s privacy policy if you have any questions about its use of your information.

Credit Card Information. As noted above, Shnorr collects credit card information when you enter into certain types of transactions requiring payment. Credit card information collected by Shnorr undergoes a tokenization process performed by our third party service provider and is not stored by Shnorr directly. The information is only used to perform the transaction and any recurring or guaranteed minimum transactions to which you have agreed.

How do we Use your Information

We may use the information that we gather about you for the following purposes:

To provide our Services to you, to communicate with you about your use of our Services, and for other customer service purposes;
To provide information that you have requested to receive from us in response to your opt-in requests;
To provide our Services at the request of our Clients;
To administer Campaigns;
To administer your account;
To send you receipts;
To provide and post results of Campaigns;
To respond to customer service inquiries;
To improve our Sites and Services by providing personalized experiences, location customization, personalized help, and instructions;
To provide you updates about our Sites and Services;
For marketing and advertising purposes; for example, we may use your information to display targeted advertisements to you on our Sites and to assist us in advertising our Services on third party websites;
To send you email, follow-up questions about your Campaign or your participation in a Campaign, news and newsletters, promotions, and/or invitations to visit the Site;
To better understand how users access and use our Sites and Services, both on an aggregated and individualized basis, and for other research purposes;
When you, if a Consumer, submit your contact information to sign up for or activate a Shnorr profile, you agree and consent that Shnorr may send you communications relating to our products, events, or recommended charities or Campaigns (unless such communication requires consent according to applicable law and subject to your ability to opt out of such communications); and
When you submit your organization’s contact information to sign up for an account with Shnorr, you agree and consent that Shnorr may send your organization communication relating to our products, events, or other business information (unless such communication requires consent according to applicable law and subject to your ability to opt out of such communications).

Clients should note that we may use information we receive or collect regarding Consumers (including without limitation via a Campaign page) in accordance with the terms of this Policy, including in the manner set forth above.

Notwithstanding the foregoing, in certain contexts, we collect information on behalf of our Clients subject to contractual requirements that limit our ability to use and transfer your information in ways that are more restricted than those in this Policy (e.g., the information be only used as necessary to provide Services to the Client and/or for other specified purposes). In those limited circumstances, your information is subject to those contractual requirements to the extent that they conflict with this Policy, subject to enforcement by the applicable Client. If your information is collected on behalf of a third party, it will be evident at the time that you provide such information. This Policy does not cover our Clients’ use of your information outside of our Services. You should contact that party directly to determine if your information is subject to such limitations on uses and to ascertain how the third party will make use of your information.

When and How does Shnorr Share Information it Receives?

Third Parties. We may share your information, including personally identifiable information, with unaffiliated and affiliated third parties.

Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your information will be subject to this Policy.

If you are using our Services to participate in a Campaign or to purchase a third party product or service, Shnorr shares the personal information that you provide with the applicable third parties in order to fulfill your request. You may receive communications, correspondence, emails, or direct mail from these entities; each such party operates independently from Shnorr and is not subject to this Policy but is subject to its own privacy policy. For example, if you donate to an organization, that organization may reach out to you to inform you how your donation was used or otherwise thank you.

Recent Donors Panel. The recent donors panel is a streamed display of actions occurring on the Sites. Unless you select the option to participate in a Campaign anonymously, your name and the amount of your contribution will be publicly displayed through the relevant Client’s recent donors panel and the recent donors panel of a fundraising team or community page.

Making a donation "anonymous" only hides your name from public activity feeds, not the underlying charitable beneficiary. If you donate anonymously through a personal or team fundraising page, your personal information will be shared with the individual fundraiser and the team fundraising captain (except for your credit card number or financial information). If you join a team to participate in a Campaign, then the team captain will also have access to your personal information (again, except for your credit card number or financial information). You consent to the foregoing and agree that we are not responsible for how these organizations or persons handle your personal information. You should visit their websites and/or contact them directly for their privacy policies and data usage practices.

Supporter Communications. As part of a Client's use of the Services, Consumers may also send emails through the Services ("Supporter Emails"). For example, personal fundraisers may send messages to their contacts through the Services in order to ask people to visit their fundraising pages and donate. They may also send emails to update donors or to thank donors for their gifts.

APIs. We make certain application programming interfaces ("APIs") available to Clients. An API (in non-technical terms) allows a Client to automatically retrieve certain information from our Sites, for use/display elsewhere (e.g., on the Client’s website, supporting fundraising system or similar). To give an example, a Client might use our API to retrieve the names and photos of the top five fundraisers for a Campaign; the Client could then display that information on a leaderboard on a different system. If you are fundraising for a Client, your name, amount raised, and goal can be retrieved by the Client through our API. If you create a team fundraising page, then your name, the team goal, and the amount raised by the team can also be retrieved by the Client through our API. If you are a Consumer who donates to a Campaign, the Client who receives your donation may display your information, such as name and amount to the Client’s own donation appreciation wall or similar acknowledgment (which would be hosted outside of Shnorr’s Services). The foregoing examples are for illustrative purposes only.

Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors, or agents who perform functions on our behalf. For example, these providers may help us administer our Sites and Applications manage and administer Campaigns, process credit card or other payments, de-duplicate data, or verify identities for fraud prevention purposes. These third parties have agreed to maintain the confidentiality, security, and integrity of your information and may be located wherever the Sites or Services are available. Where required by law, these companies agree to only use such information for the purposes for which they have been engaged by us unless you expressly permit them to use your information for other purposes. We now require service providers to whom we disclose Personal Data (as defined below) and who are not subject to laws based on the European Union General Data Protection Regulation to either subscribe to the United States / European Union Privacy Shield principles or agree to provide at least the same level of protection for Personal Data as is required by the relevant Privacy Shield principles, for instance by entering into Standard Contractual Clauses, as promulgated by the European Commission. If the third party does not comply with its privacy obligations, Shnorr will take commercially reasonable steps to prevent or stop the use or disclosure of Personal Data. You can find more information on the Privacy Shield program by visiting https://www.privacyshield.gov/. For purposes of this Policy, “Personal Data” means information that (i) is transferred from the EU to the United States, (ii) is recorded in any form, (iii) is about, or relates to, an identified or identifiable consumer, customer, supplier or other individual, and (iv) can be linked to that consumer, customer supplier, or other individual.

Other Non-Affiliated Third Parties. We may disclose the information that we collect about you to non-affiliated third parties (with your consent, if consent is required by law), such as promotional partners and others with whom we have marketing or other relationships. This information may help us to determine what advertisements to direct to you, to place on our website, and where to advertise our Services. As discussed in the advertising section below, you have the ability to opt-out of certain uses of your information. You also have the ability to opt-in to receiving certain information from us and non-affiliated third parties.

Supplemental Service Partners. By purchasing or registering for products or services offered by third parties as a result of your interaction with the Services or use of the Sites, electing to receive communications (such as emails) or electing to participate in surveys, contests, sweepstakes, or other programs offered or sponsored by third parties on the Site, you consent to our providing your personal information to those third parties, and you agree that we are not responsible or liable for any of their actions or omissions. When you provide your information in this manner, it will be apparent that you are providing it to a third party. Those third parties may use your personal information in accordance with their own privacy policies. You will need to contact those third parties to instruct them directly regarding your preferences for the use of your personal information by them. Additionally, you agree that we will have the right to use and disclose all such information submitted by you to such third parties in the same manner in which we have the right to use and disclose all other information submitted by you directly to us.

Strategic Partners. Shnorr has integration relationships with third-party companies and individuals ("Partners"). These relationships extend the functionality of the Services and the Partner’s application or service ("Integrated Service") by allowing the Services and the Integrated Service to exchange Consumer data among other things and to establish linked business processes between the two. Consumers or Clients who pay Shnorr for use of the Services and use an Integrated Service are considered customers of both Shnorr and the Partner. Shnorr and the Partner may share Consumer or Client contact, account, financial and billing information, and business data with respect to their integrated business relationship with the Consumer or Client. The sharing of this information allows Shnorr and the Partner to establish the identity of the shared customer and, in some cases, determine referral fees owed. This sharing may also allow the Partner to provide consolidated billing services to the shared customer and allow for the enhanced functionality of the Integrated Service. Those Partners may use your personal information in accordance with their own privacy policies. You will need to contact those third parties to instruct them directly regarding your preferences for the use of your personal information by them. Additionally, you agree that we will have the right to use and disclose all such information submitted by you to such third parties in the same manner in which we have the right to use and disclose all other information submitted by you directly to us.

Affiliate and Referral Partners. Shnorr has referral relationships with third-party companies and individuals ("Referral Partners") who refer customers to Shnorr. Shnorr and a Referral Partner may share certain information with respect to a Consumer or Client that is referred by Shnorr or a Referral Partner to allow Shnorr and the Referral Partner to establish the identity of the shared Consumer or Client and determine referral fees owed.

We also may share your information for the following reasons:

Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the acquiring company. You acknowledge and agree that any successor to or acquirer of Shnorr will continue to have the right to use your information in accordance with the terms of this Policy.
In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena.
To Protect Shnorr and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms of Use or this Policy.
Aggregate and Anonymized Information. We may share aggregated or anonymized information about Clients and Consumers with third parties for marketing, advertising, research, or similar purposes. For example, if we display advertisements on behalf of a third party, we may share aggregated, demographic information with that third party about the Consumers and/or Clients to whom we displayed the advertisements. In addition, we may publish long-form research reports and blog posts summarizing aggregated data describing behaviors of Clients and Consumers on our Sites, Applications, and Services. We may also publish datasets containing aggregated Client and/or Consumer data to support replication of the published research results.

Third Party Applications. Third party applications, such as Instagram, Facebook, Twitter, Pinterest, or Google buttons, may be available on our Sites. The owners or providers of those third party applications may collect personally identifiable information from you. Their collection of information is bound by their own information collection policies and practices. Your interactions with third party applications on our Sites may be shared with others within your social network. We are not responsible for the collection and use of your information by such third parties.

Our Sites include social media features, such as the Facebook “comment” button and widgets such as the “share this button” or interactive mini-programs. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing such features.

Network Advertisers. Network advertisers are third parties that display advertisements based on your visits to our Sites and other websites you have visited. This enables us and these third parties to target advertisements to you for products and services in which you might be interested. These third party services may use cookies, JavaScript, and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third party technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third parties with information, including both personally identifiable and non-personally identifiable information, about your usage of our Sites and our Services.

We use Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity may also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

Third Party Links. At times, our Sites and Platforms may contain links to other third party websites. Any access to and use of such linked websites is not governed by this Policy, but, is instead governed by the privacy policies of those third party websites, and we are not responsible for the information practices of such third party websites.

How Secure is Information About Me?

We have implemented and maintain appropriate technical and organizational security measures, policies, and procedures designed to reduce the risk of accidental destruction or loss, or unauthorized disclosure or access to such information appropriate to the nature of the information, concerned, including,

where appropriate, password protection, encryption, tokenization, and secure socket layering to protect our Sites;
following strict security procedures in the storage and disclosure of your personal information to prevent unauthorized access to it; and
placing confidentiality requirements on our employees and service providers.

Please be aware that despite our best efforts, no data security measures can guarantee 100% security all of the time. Please keep this in mind when disclosing any of your personal information via the Internet.

As the security of personal information depends in part on the security of the computer you use to communicate with us and the security you use to protect usernames and passwords, you should take steps to protect against unauthorized access to your password, computer, and web-enabled devices, among other things, by signing off after using a shared computer, inserting a password on your web-enabled device, choosing a password that nobody else knows or can easily guess, keeping your password private, and periodically changing your password. You should never share your login information with others. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity.

We endeavor to store your personal information for only as long as is reasonably necessary for the purposes for which it was collected, as explained in this Policy. Where your information is no longer needed, we will dispose of it in a secure manner. In some circumstances, we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements.

In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

Can I Access and Modify my Personal Information?

Upon request, Shnorr will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us here.

If your personal information changes, or if you no longer desire our service, you may correct, update, delete/remove, or ask to have it removed from a public forum or testimonial by making the change within your account settings or by contacting us via one of the methods listed in this Policy. We will respond to your request to access within 30 days. Please note that copies of information that you have updated, modified, or deleted may continue to reside in our systems for a period of time. Also, you may not be able to remove your personal information from archived web pages that we no longer maintain, such as information related to a Campaign in which you participated, where that information is displayed by our Client or third party to whom the Client provided your information. In the event we are unable to complete your access request, we will let you know that we are unable to do so and why. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.

If your information has been shared with a third party, as described above, or collected on behalf of a Client, then that third party has received their own copy of your data. If you have been contacted by one of these third parties, or one of our Clients, and wish to correct or request they delete your information, please contact them directly.

What Choices Do I have Regarding My Information?

Shnorr may send you emails from time to time, for example, to ask you about a Campaign in which you participated. When you use our Services, you may have the option of signing up for news and offers from us or other third parties, which may include information about Campaigns, our newsletter, or other items that we (or third parties) believe may be of interest to you. If, at any time, you would like to stop receiving the information that you have requested to receive from us, you may follow the opt-out instructions contained in any such email. Please note that it may take up to 10 business days for us to process opt-out requests.

To opt out of products, programs, Services, or offers from our affiliates and trusted partners, please contact us here or log into your account and update your subscription preferences, where that functionality is made available to you. If you opt out of receiving emails or promotions from us, we still may send you emails about your account or any Services you have requested or received from us, or for other customer services purposes, including sending you receipts. In addition, you may still receive emails sent by our Clients through means other than our system. Further, if you opt out of receiving information related to a particular Campaign, you will still receive Shnorr communications and communications from other organizations whose Campaigns you have participated in or who have otherwise obtained your email address. As a result, as a Consumer, you may have to unsubscribe from multiple emails before you stop receiving all communications related to Campaigns in which you have participated through our Services.

As a Client, by electing to stop receiving communications from us or through our system you will no longer receive any updates on your account or on Campaigns in which you are participating or have participated, including communications regarding receipts and refunds. We do not recommend that you do this unless you plan to no longer use the Services, have not participated in a Campaign for which you need a receipt, are not currently participating in a Campaign, or are not currently organizing a Campaign and will have no need to receive further communications from us or through our system. If you are a Client, note that you may not be able to unsubscribe from update communications about the Services unless you close your account.

Even after you opt out of all communications, we will retain your information in accordance with this Policy; however, we will no longer use it to contact you, unless required by law or unless you later provide your information to us. However, our Clients who have received your information in accordance with this Policy may still use that information to contact you in accordance with their own privacy policies, but they may not use our system to do so.

If you would like to delete your account with us, you may do so by contacting us here and specifying which account(s) to delete.

International Data Transfer

The Services are hosted in the United States and are governed by United States law. If you are visiting the Sites or using the Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers and databases are located. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country.

By using the Sites and Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Policy. We will take appropriate steps to cause that transfers of personal information are in accordance with applicable law, are carefully managed to protect your privacy rights and interests and limited to countries which are recognized as providing an adequate level of legal protection or where alternative adequate arrangements are in place to protect your privacy rights.

In certain situations, Shnorr may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you are located in the EUROPEAN ECONOMIC AREA (EEA), UNITED KINGDOM OR SWITZERLAND

THIS SECTION ONLY APPLIES TO USERS OF OUR SERVICES THAT ARE LOCATED IN THE EUROPEAN ECONOMIC AREA, UNITED KINGDOM OR SWITZERLAND AT THE TIME OF DATA COLLECTION. WE MAY ASK YOU TO IDENTIFY WHICH COUNTRY YOU ARE LOCATED IN WHEN YOU USE SOME OF OUR PRODUCTS OR SERVICES, OR WE MAY RELY ON YOUR IP ADDRESS TO IDENTIFY YOUR COUNTRY LOCATION.

Shnorr processes Personal Data as a “processor,” “joint controller,” and as a “controller” under the European Union’s General Data Protection Regulation. A “controller” is an entity that determines the purposes for which and the manner in which any personal information is processed. Any third parties that act as our service providers are “data processors” that handle your personal information in accordance with our instructions. With respect to your personal data that you enter or that is received through our websites that is not directly related to a Customer’s Campaign, Shnorr is the controller. To the extent that Shnorr receives personal information from a Consumer through a Customer’s Campaign, Shnorr and its Customer are joint data controllers. This means that you may choose to exercise your rights, including as described below, with Shnorr or the relevant Shnorr Customer. Please do not hesitate to contact us if you are unsure who the relevant Shnorr Customer is for a given Campaign or would like their contact information.

If you are in the EEA, United Kingdom or Switzerland, you have the following rights (where applicable):

Access: You have the right to request a copy of the information we are processing about you;
Rectification: You have the right to have incomplete or inaccurate information that we process about you rectified;
Deletion: You have the right to request that we delete information that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise, or defend legal claims;
Restriction. You have the right to restrict our processing of your information where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it;
Portability. You have the right to obtain information we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) information which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you;
Objection. Where the legal basis for processing your information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests, or if we need to continue to process the data for the establishment, exercise, or defense of a legal claim;
Withdrawing consent: If you have consented to our processing of your information, you have the right to withdraw your consent at any time, free of charge. This includes where you wish to opt out from marketing messages.

You can make a request to exercise any of these rights in relation to your information by contacting us here. For your own privacy and security, at our discretion, we may require you to prove your identity before providing the requested information. Please note that we may take up to 30 days to fulfill such a request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. A list of local data protection authorities in European countries is available here.

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

Children Under 13 (Or 16 in the EU)

Our Sites are for general audiences, and we do not knowingly market to, or solicit information, accept service or collect information from or about children or sell products to children under the age of 13 (or 16 in the EU). If you are under the age of 13 (or 16 in the EU), you must ask your parent or guardian to use our Sites directly, on your behalf. Furthermore, we may restrict entries to any contests, sweepstakes, or promotions to those who are at least 18 years of age. If we become aware that any person submitting information to the Sites is under the age of 13 (or 16 in the EU), we will attempt to delete the account and any related information as soon as possible. By using the Sites, you hereby represent that you are at least 13 years old (or 16 in the EU).

Terms of Use

Your use of our Sites or Services, as well as any dispute over privacy, are subject to this Policy and our Terms of Service, https://shnorr.com/terms, including applicable limitations on damages and the resolution of disputes.

Special Information for California Residents

California Consumer Privacy Act Rights. Under the California Consumer Privacy Act (“CCPA”) California residents have certain rights regarding their personally identifiable information. If you would like to exercise these rights on or after January 1, 2020, please contact us here. For your own privacy and security, at our discretion, we may require you to prove your identity before providing the requested information. It may take us some time to respond to your request, but we will do so within the requirements of the CCPA.

This Policy provides you disclosure regarding the personal information we collect from you and the purposes for doing so. Please see the What Information do we Collect about You and Why?

We do not sell your personal information as provided under the CCPA.
Right to request disclosure as to personal information Shnorr has collected about you:
- Upon a verifiable request, contact us here, we will disclose to you the items listed below, one or more of which may be provided by reference to this Policy:
- The categories of personal information it has collected about you.
- The categories of sources from which the personal information was collected.
- The business purpose behind collecting personal information.
- The categories of third parties with whom Shnorr has shared the information.
- The specific pieces of personal information Shnorr has collected about you.
Right to request deletion: upon a verifiable request, made contacting us here, we will delete personal information we have regarding you and direct our service providers to delete your personal information from their records, to the extent provided by the CCPA.
Right to be free from discrimination: Shnorr will not discriminate against you for exercising any of your rights under the CCPA. Please keep in mind that under certain circumstances, we may charge you a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to you by your personal information.

Changes to this Policy

We may change this Policy from time to time, so be sure to check back periodically. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to notify you in advance of such change, by highlighting the change on the Sites or by sending an email to you at the email address that you have registered with us. Your continued use of the Services after any changes or revisions to this Policy will indicate your agreement with the terms of the revised Policy.